Further to Hellenic Capital Market Commission’s approval of the registration of EN.A. as an SME Growth Market on 04.03.2026, the Athens Exchange has launched a comprehensive overhaul of its Alternative Market. Effective as of 16.03.2026, the new EN.A. Growth Operating Rules fully replace the 2019 framework and represent the most significant upgrade to Greece’s SME capital market in years. Whether you are contemplating a listing, already operating as an issuer, or hold significant stake in an SME, the following overview hightlights what you need to know.
A unified market with a simplified structure
EN.A. Growth is no longer divided into sub-segments such as EN.A. PLUS and EN.A. STEP. It now operates as a single multilateral trading facility, with clear instrument categories: shares, fixed-income securities, rights and warrants, and a new “special characteristics” category for issuers facing specific financial challenges or not meeting the ongoing free-float adequacy.
Easier entry but with stronger safeguards
The initial free-float requirement has been reduced from 15% to 10%, while the distribution requirement has been increased from 50 to 70 persons (excluding principal shareholders), with a minimum 5% continuous free float now required for common shares. Further, companies without a full two-year track record may now apply on the basis of an audited business plan.
Stronger corporate governance from day one
EN.A. Growth now requires, as a condition of admission and on an ongoing basis, an internal operating regulation, at least one non-executive board member, a corporate website with an investor relations section, and a designated shareholder and announcements officer.
Enhanced transparency and disclosure
The new EN.A. Growth rules introduce several disclosure obligations, such as annual performance commentary alongside the companies’ annual financial statements, use-of-proceeds tracking, large dilutive issuances, where the companies must publish an information note, and shareholding change notifications for shareholders holding more than 10% of voting rights.
Refined lock-ups
The lock-up for principal shareholders (≥5%) of loss-making companies has been shortened from one year to six months, with transfers capped at 25% of the relevant holding. Regulated venture capital companies (in Greek, “Ε.Κ.Ε.Σ.”) are now expressly exempt from the lock-up restrictions applying to principal shareholders. This means that a VC fund that has backed an SME can use EN.A. Growth as a disposal venue from day one of trading, without being subject to the 25% transfer cap.
The “special characteristics” category - an early-warning system
Shares are moved into this early-warning category where negative equity exists at year-end, a rehabilitation filing has been made, serious going-concern doubts emerge, or the company fails the ongoing 5% free-float test, enabling investors to make timely exit decisions before further deterioration.
Clearer suspension and delisting rules
Grounds for suspension are now explicitly enumerated (missed deadlines, failure to respond to exchange queries, dissolution, bankruptcy, loss of adviser). Compulsory delisting follows where the situation becomes irreversible or suspension persists for six months (extendable to one year). Voluntary delisting requires a 95% supermajority at the general meeting, unless the purpose is to transfer to the regulated market.
Transitional timeline
The rules are already in force, but key obligations are phased in for existing issuers. Organisational requirements, use-of-proceeds disclosures and the ongoing 5% free-float obligation apply from 01.01.2027. The first ''special characteristics review'', based on 2026 financials, takes place from 01.05.2027, and the first formal free-float check, based on 2027 dispersion data, will follow from 01.01.2028.
What this means in practice
For companies considering a listing, the path to EN.A. Growth is clearer, with lower initial dispersion thresholds but more structured governance and disclosure expectations from day one. For existing issuers, 2026 is the year to prepare: upgrade internal regulations, appoint a non-executive director, and set up use-of-proceeds tracking. For shareholders, the reforms should translate into better information, stronger governance, and a formal early-warning system for companies in financial difficulty. EN.A. Growth is positioning itself as a credible, EU-aligned SME Growth Market - one that balances accessibility with investor protection. Coupled with the tax incentive tools recently introduced under Greek law 5193/2025, these developments make the alternative market of the Athens Exchange an increasingly attractive avenue for SMEs seeking to raise capital, draw in strategic partners, and chart a sustainable path to growth.